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Case 1:20-cr-00330-PAE Document 218 Filed 04/19/21 Page1of8 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmilaw.com jpagliuca@hmilaw.com HADDON MORGAN FOREMAN April 15, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: Response to Government’s April 5, 2021 Letter re. Ms. Maxwell’s Rule 17 Subpoena United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The government’s superficial analysis of a Fed. R. Crim. P. 17 subpoena is neither accurate nor informative. The collection of various cliché phrases about Rule 17 subpoenas, selectively gathered from cases inapplicable here, is unpersuasive, and the Court should deny the requested relief because: (1) the government lacks standing to interfere with subpoenas issued to the third party respondents; and (2) this intrusion is yet another attempt to infringe on Ms. Maxwell’s constitutional rights to effective assistance of counsel, a fair trial, and due process, all in violation of the 5“ and 6" Amendments to the United States Constitution. I. Background In February 2016 (and likely at least one other time in the weeks and months that followed), lawyers representing numerous civil litigants, including then-Plaintiff Virginia Giuffre, met with the government to foment an indictment of Ms. Maxwell. These lawyers and their clients sought a tactical advantage in their civil litigations, worth millions of dollars. This first meeting was followed up by additional communications from these lawyers to the government. Subsequently, and unknown to Ms. Maxwell, the government brokered a deal DOJ-OGR-00003853